ML20003D489

Proposed Changes to Sections 2.0,3.0 & 5.0.Discussion, Comparison of STS W/Proposed Tech Specs & Justification for Class III Classification Encl

ML20003D489
Person / Time
Site:	Fort Calhoun
Issue date:	03/25/1981
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20003D479	List: ML20003D478 ML20003D485 ML20003D489
References
NUDOCS 8103270416
Download: ML20003D489 (26)

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.0 LIMITING CONDITIONS FOR OPERATION 2.18 Shock Suppressors (Snubbers)

Applicability This specification applies to safety-related shock suppressors (snubbers). Operatieg Modes 1, 2, and 3 (Operating Modes 4 and 5 for snubbers located on systems required operable in those Operating Modes).

Objective The objective is to specify modes of reactor operation for given conditions of safety-releted snubbers.

Specifications (1) During all modes of operation, except Cold Shutdown (Oper-ating Mode 4) and Refueling (Operating Mode 5), all snubbers listed in Table 2-6 (a) and (b) shall be operable except as noted in 2.18(2) through 2.18(4) below.

(2) With one or more snubbers inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> re-place or restore the inoperable snubber (s) to operable status and perform an engineering evaluation per Specifi-cation 3.14(3) on the supported component or declare che supported system inoperable end follow the appropriate actions specified in the Technical Specifications for that system.

(3) A snubber may be removed for surveillance in accordance with Section 3.14(3) of these Technical Specifications, provided the following conditions are met:

(a) A given snubber station shall not be without an operable snubber for more than two hours during surveillance of attendant snubber. A snubber may be replaced by an operable snubber during surveillance and repair.

(b) No other snubber station, containing snubbers listed in Table 2-6 (a) and (b), is known to be inoperable. .

(c) Only one snubber station, containing snubbers listed in Table 2-6 (a) and (b), shall be removed for test-ing at a time to ensure ri2t no two saubber stations are without an operab?e snubber during the sr .e time interval.

(4) Snubbers may be added, changed, or deleted from Table 2-6 (a) and (b) without prior licensing amendments provided an accepted engineering analysis justifies each change.

Deletions will be allowed only after an independent review of the engineering justification is performed and the deletions are approved by SARC. Any revisions to Table 2-6 04W m(a)ent and (b) will be included in subsequent licensing amend-810327 requests.

Amendment No. 27, 48 2-73 ATTACHMENT A

,* .-

2.0 LIMITING CONDITIONS FOR OPERATION 2.18 Shock Suppressors (Snubbers) l Basis Snubbers are designed to prevent unrestrained pipe motion under

, dynamic loads as might occur during an earthquake or severe transient, while allowing normal thermal motion during startup or shutdown. The consequence of an inoperable snubber is an in-crease in the probability of structural damage to piping as a result of a seismic, oi other event, initiating dynamic loads.

It is therefore required that all snutbers required to protect the primary coolant system or any other safety system or com-ponent be operable during reactor operation.

Because the snubber protection is required only during low ,

probability events, an inoperable period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed for repairs or replacements and an inoperable period of two hours is allowed for surveillance.

Table 2-6 (a) and (b) lists the snubbers that are on safety-related systems. The snubbers that are listed as " Inaccessible During Nor-mal Operation" are located inside of the containment building and would require a significant expenditure in man-rems to inspect on a periodic basis. Revisions may be made to Table 2-6 (a) and (b) without prior notice provided that an engineering analysis justi-fies these changes.

Those snubbers listed as " Difficult to Remove for Functional Testing" are so listed because they are either:

(1) rated at greater than 50,000 lbs. force, (2) inaccessible due to surrounding structures, or (3) located such that an excessive amount of time and effore would be required to remove them for testing.

i I

Amendment No. 21, 48 2-74 i

, ,. TABLE 2-6 (a)

ACCESSIBILITY OF SAFETY-RELATED SYSTEM HYDRAULIC SNUBBERS Located Accessible In High Difficult to During Inaccessible Radiation Remove for

• Snubber Normal During Normal Areas During Functional No. Elevation Operation Operation Shutdown Testing ACS-18 996' 8" X ACS-112 1040' 0" X X ACS-113 1040' 0" X X ACS-113A 1040' 0" X X ACS-116 1031' 4" X ACS-117 1031' 4" X ACS-116 1031' 4" Y ACS-121 1031' 4" X ACS-123 1031' 4" X ACS-127A 1040' 0" X X ACS-128 1040' 0" X X ACS-299 1056' 4-11/16" X ACS-299A 1056' 6" X ACS-302 1056' 4-11/16" X ACS-304 1056' 4-11/16" X ACS-305 1056' 4-11/16" X ACS-306 1056' 4-11/16" X ACS-307 1056' 4-11/16" X ACS-313 1054' 11" X ACS-385 987' Sk" X i

FWS-1 Top 1038' 6" X X FWS-1 l Bottom 1038' 6" X X FWS-1A 1033' 6" X ,

X FWS-1B 1033' 5\" X X WS-IC 1033' 5 " X X FWS-2 l Top 1038' 6" X X ,

! FWS-2 -

Botton 1038' 6" X X Amendment No. 27 2-75 L - -

.. TABII 2-6 (a)

- (Continued)

Located Accessible In High Difficult to During Inaccessible Radiation Remove for

• Snubber Normal During Normal Areas During Functional No. Elevation Operation Operation Shutdown Testing WS-2A 1038' 6" X X WS-2B 1038' 5\" X X WS-2C 1038' 55" X X WS-3B-North 1038' 5\" X WS-3B-South 1033' 6" X WS-7D-North 1038' 6" X WS-7D-South 1038' 6" X WS-28 1002' 6" X WS-29A 1002' 6" X WS-30 1002' 6" X WS-32 1005' 1" X WS-32A 1005' 1" X i~ WS-33 1001' 6" X WS-34 1001' 6" X WS-35 1005' 5" X WS-36 1005' 5" X Wd-37 1005' 5" X WS-38 1010' 0" X WS-39 1012' 1\" X WS-64 1043' 0" X WS-64A 1041' 0" X WS-64B 1041' 0" X-WS-65 1049' 6" X WS-66 1049' 6" X WS-67 1049' 6" X WS 1049' 6" X WS-68A - 1049' 6". X ,

WS-69 1049' 6" X WS-71 -1037' 6" X Amendment No. ' 27 2-76

TABLE 2-6 (a)

(Continued) located 4ccessible In High Difficult to During Inaccessible Radiation Remove for

• Saubber Normal During Normal Areas During Functional No. Elevation Operation Opcration Shutdown Testing WS-74 1053' 0" X WS-75A 1053' 0" X WS-7 ' 1038' 4" X WS-79 1049' 6" X WS-80 1049' 6" X WS-81 1049' 6" X WS-83 1033' 4" X WS-86A 999' 0" X WS-87 999' 0" X WS-88 999' 0" X WS-88A 999' 0" X WS-89 1002' 6" X WS-90 1001' 6" X WS-90A 1005' 6-5/8" X WS-91 1019' 0" X WS-92 1019' 0" X WS-92A 1026' 0" X WS-93 1032' 0" X WS-94 1032' 0" X WS-95 1032' 0" X WS-96 1032' 0" X X WS-97 1032' 0" X X WS-98 1032' 0" X X l

WS-100 1039' 0" X WS-101 1039' 0" X MSS-1 1054' 7" X X MSS-2 1054' 8 " X X MSS-3 '038' 0" X MSS-L-Top 1038' 6" X X Amendment No. 27 2-77

, ,. TALLE 2-6 (c)

'. (Con;inu:d)

Located Accessible In High Difiicult to During Inaccessible Radiation Remove for

• Snubber Normal During Normal Areas During Functional N?. Elevation Operation Operation Shutdown Testing MSS-4 Bottom 1038' 6" X X MS-5 1054' 7" X X MSS-6 1054' 8\" X X MSS-7 1038' 6" X X MSS-8-Top 1038' 6" X X MSS Bottom 1038' 6" X X MSS-8A 1038' 6" X X MSS-8B 1038' 6" X X MSS-8C 1038' 6" X X MSS-8D 1038' 6" X X MSS-9 1040' 7" X MSS-9A 1040' 7" X MSS-9B-North 1033' 6" X MSS-9B-South 1033' 6" X MSS-13 1040' 7" X MSS-13A-East 1040' 0" X MSS-13a-West 1040' 0" X HSS-13B-North 1038' 6" X MSS-13B-South 1038' 6" X RCP-Al 1016' 0" X RCP-A2 1016' 0" X RCP-A3 1016' 0" X RCP-A4 1016' 0" X RCP-B1 1016' 0" X RCP-B2 1016' 0" X RCP-B3 1016' 0" X RCP-B4 1016' 0" X Amendment No. 27 2-78

. .. TABLE 2-6(n)

. (Continu::d)

Located Accessible In High Difficult to During Inaccessible Radiation Remove for

• Snubber Normal During Normal Areas During Functicnal No. Elevation Operation Operation Shutdown Testing RCS-52 1007' 9" X RWS-79 1046' 0" X X RWS-128 998' 8 " X RWS-130 998' 8\" X RWS-131 998' 8\" X SG-Al 1049' 0" X X SG-A2 1049' 0" X X SG-A3 1049' 0" X X SG-A4 1049' 0" X X SG-B1 1049' 0" X X SG-B2 1049' 0" X X SG-B3 1049' 0" X X SG-B4 1049' 0" X X SIS-1 979' 6" X SIS-1A 979' 6" X SIS-3 979' 6" X SIS-4 979' 6" X SIS-4A 979' 6" X SIS-5 979' 6" X SIS-5A 979' 6" X

, 'S-6 979' 6" X

,;S-6A 979' 6" X l SIS-7 979' 6" X SIS-8 979' 4" X SIS-8B 979' 6" X SIS-8C 979' 6" X SIS-9 979' 6" X SIS-9A 979' 6" X

SIS-9B 979' 6" X SIS-10 983' 6" X SIS-ll 983' 6" X ,

SIS-16 981' 6" X SIS-16A 981' 6" X.

SIS-17 979' 6" X Amendment No. 27 2-81

TABLE 2-6(a)

(Continued)

Located Accessible In High Difficult to During Inaccessible Radiation Remove for

• Snubber Normal During Normal Areas During Functional No. Elevation Operation Operation Shutdown Testing SIS-17A 979' 6" X SIS-18 979' 6" X SIS-19 979' 6" X SIS-20 979' 6" X SIS-21 979' 6" X SIS-21A 981' 6" X SIS-21B 981' 6" X SIS-2IC 981' 6" X SIS-22 981' 6" X SIS-24 983' 6" X SIS-24A 983' 6" X SIS-26 979' 6" X SIS-27 981' 6" X

' SIS-27A- 981' 6" X SIS-27B 981' 6" X SIS-28 980' 0" X SIS-28A 980' 0" X SIS-29 980' 0" X 979' 6" SIS-30 X SIS-30A 979' 6" X

, S-31 981' 6" X aIS-31A 981' 6" X SIS-32 980' 0" X l SIS-32A 980' 0" X SIS-32B 980' 0" X SIS-33-Top 981' 6" X SIS .

Botton 981' 6" X X l'

980' 0" SIS-34 X

. SIS-35-Top 980' 0" X SIS ,

Botton 980' 0" X SIS-36-Top- 974' 6" X

' Amendment No. 27 2-82

TABLE 2-6(c)

(Continu:d)

Located Accessible In High Difficult to During Inaccessible Radiation Remove for CSnubber hormal During Normal Areas Dur;.ng Functional No. Elevation Operation Operation Shutdow*. Testing SIS Bottom 974' 6" X SIS Top 981' 6" X SIS Bottom 981' 6" X SIS-38 981' 6" X X SIS-38B 98I' 6" X X SIS-38C 981' 6" X X SIS Tap 973' 0" X SIS Bottom 973' 0" X SIS-39A 973' 0" X SIS Top 981' 6" X SIS Bottom 981' 6" X SIS-41A 979' 6" X SIS-42 979' 6" X IS-42A 979' 6" X SIS-43 979' 6" X SIS-43A 979' 6" X SIS-44 979' 6" X SIS-o4A 979' 6" X SIS-44B 979' 6" X SIS-44C 979' 6" X SIS-45 974' 6" X SIS-45A 979' 6" X SIS-46 979' 6" X i SIS-47 979' 6" X .

SIS-48 979' 6" X SIS-49 979' 6" X SIS-50 979' 6" X Amendment No. 27 2-83

. TABLE 2-6(c)

(C:ntinu;d)

Loccted Accessible In High Difficult to During Inacce:Sible Radiation Remove for CSnubber Normal During Normal Areas During Functional No. Elevation Operation Operation Shutdown Testing SIS-53 997' 6" X SIS-53A 997' 6" X SIS-54 996' 6" X SIS-55 996' 6" X SIS-56 996' 6" X SIS-56A 996' 6" X SIS-57 995' 11-3/8" X SIS-58 995' 11-3/8" X SIS-59 996' 6" X SIS-60 996' 6" X SIS-63 990' 6" X SIS-64 990' 6" X SIS-65 990' 9" X SIS-66 1000' 0" X SIS-67 1000' 0" X SIS-68 1001' 9-3/8" X SIS-69 1003' 6" X X SIS-70 1000' 0" X SIS-71A 1002' 8" X SIS-72 1002' 8" X S-73 1002' 8" X SIS-74 1002' 8" X SIS-74A 1002' 8" X SIS-75 1002' 8" X SIS-76 997' 6" X SIS-76A 997' 6" X SIS-77 991' 0" X SIS-77A 991' 0" X SIS-78 991' 0" X SIS-79 1501' 4" X SIS-79A 1001' 4" X ,

Amend =ent No. 27 2-84

TABLE 2-6(a)

(Continu;d)

Loccted Accessible In High Difficult to During Inaccessible Radiation Remove for

< Snubber Normal During Normal Areas During Functional N2 Elevation Operation Operation Shutdown Testing ___

SIS-101 991' 0" X SIS-101A 991' 0" X SIS-102 991' 0" X SIS-103 1001' 4" X SIS-104 1001' 4" X SIS-104A 1001' 4" X SIS-104B 1001' 4" X SIS-115 1009' 5-3/4" X SIS-116 1009' 5-3/4" X SIS-117 1009' 5-3/4" X SIS-117A 1009' 5-3/4" X SIS-118 1009' 5-3/4" X SIS-118A 1009' 5-3/4" X SIS-119 1006' 4-1/2" X Top SIS-119 1006' 4-1/2" X Bottom SIS-120 1006' 4-1/2" X SIS-121 1007' 10" X SIS-122 1003' 0-1/8" X

."S-122A 1003' 0-1/3" X

~

21S-123 1003' 0-1/3" X SIS-124 1010' 4" X SIS-127 1010' 4" X SIS-127A 1010' 10-1/2" X SIS-129 1005' 5" X SIS-130 1008' 2" X SIS-132 1008' 2" X l SIS-134 1003' 0" X SIS-135 1003' 0" X SIS-140 1008' 10" X SIS-ISO 1008' 10" X SIS-159A 1004' 3-1/6" X SIS-161 1014' 0" X Amendment No. 27 2-86

TABLE 2-6(m)

(Continu:d)

Located Accessible In High Difficult to During Inaccessible Radiation Remove for

• Snubber Normal During Normal Areas During Functional N9 Elevation Operation Operation Shutdown Testing SIS-162 1014' 6" X SIS-164 1014' 0" X SIS-165 1014' 6" X SIS-165A 1014' 6" 2 Top SIS-165A 1014' 6" X Bottom SIS-166 1014' 6" X SIS-167 1014' 6" X SIS-168 1014' 6" X SIS-168A 1014' 6" X Top SIS-168A 1014' 6" X Bottom SIS-169 1007' 7" X SIS-169A 1007' 7" X SIS-170 1007' 8" X SIS-170A 1007' 5" X SIS-172 1032' 0" X SIS-173 1036' 8" X

. S-174 1049' 2" X SIS-174A 1049' 6" X SIS-174B 1051' 7-1/4" X X SIS-174C 1052' 6" X X SIS-174D 1063' 7-1/4" X X SIS-174E 1064' 6" X X SIS-175 1057' 0" X X SIS-175A 1056' 5-1/2" X SIS-176 1064' 6" X X SIS-176B 1052' 6" X X SIS-1768: 1051' 7-1/4" X X SIS-176ii 1064' 6" X X SIS-176E 1063' 7-1/4" X X SIS-176G 1074' 0" X X SIS-176F 1074' 0" X X SIS-178 981' 6" X Amendment No. H 48 2-87

TABLE 2-6(c)

(Continu d)

Located Accessible In High Difficult to During Inaccessible Radiatica Re:ove for

• Snubber Nor=al During Norcal Areas During Functional No. Elevation Operation Operation Shutdown Testing SIS-183 1055' 9-1/2" X SIS-184 979' 6" X SIS-185 979' 6" X SIS-187 983' 6" X SIS-188 988' 6" X SIS-202 1009' 0" X SIS-204 995' 0" X SIS-205 979' 6" X SIS-206 983' 6" X SIS-208 1003' 1-1/8" X VDS-107 1004' 0" X WDS-122- 991' 6" X Right WDS-122- 991' 6" X Left NOTE: Modifications to this table due to changes in high radiation areas should be submitted to the NRC as part of the next licensing amendment request.

2 Location ACS Auxiliary Coolant System FES Feedwater System MSS Mrin Steam S); ten 1(CP Reactor Coolant Pu=p 3 CS Reactor Coolant System

- '1%S Rav Vater System SG Steam Generator ,

SIS Safety Injection Systen VDS Vaste Disposal System Amendment No. 27 2-88

TABLE 2-6(b)

ACCESSIBILITY OF SAFETY-RELATED SYSTEM MECHANICAL SNUBBERS Located Accessible In High Difficult to During Inaccessible Radiation Remove for OSnubber Normal During Normal Areas During Functional No. Elevation Operation Operation Shutdown Testing HCV-327-S 1025' X HCV-329-S 1025' X HCV-331-S 1025' X HCV-333-S 1025' X HCV-1040-S-1 1041' X HCV-1040-S-2 1041' X HCV-1040-S-3 1041' X HCV-1040-S-4 1041' X HCV-1040-S-5 1041' X RCS-3A 996' X RCS-16 1015' X RCS-29 1047' X RCS-29A 1045' X SIS-112-C 1111'-6" X SIS-112-D 1111'-6" X SIS-112-E 1111'-6" X SIS-112-F 1111'-6" X SIS-114-A 1074' X

'IS-114-B 1074' X

.S-114-E 1074' X SIS-114-F 1074' X 0

2-88a

i 3.0 SURVEILLANCE REQUIREMENTS 3.14 Shock Suppressors (Snubbers)

Applicability This specification applies to all hydraulic snubbers on the reactor coolant and safety-related systems listed in Table 2-6 (a) and (b).

Objective The objective of this specification is to insure the overall integrity and operability of safety-related hydraulic snubbers.

Specifications (1) All hydraulic snubbers whose seal material has been de-monstrated by operating experience, lab testine or analysis to be compatible with the operating environment shall be visually inspected. This inspection shall include, but not necessarily be. limited to, inspection of the hydraulic fluid reservoir, fluid connections, and linkage connections to the piping and anchor to verify snubber operability. In those locations where snubber movement can be manually induced without disconnecting the snubber, verify that the snubber has freedom of movement and is not frozen up.

[ Visual inspections shall be performed in accordance with the following schedule:

Number of Hydraulic Snubbers Found Next Required Inoperable.During Inspection or Inspection During Inspection Interval Interval r

O 18 months i 25%

l 1 12 months i 25%

2 6 months i 25%

l 3, 4 124 days i 25%

l 5,6,7 62 days i 25%

>8 31 days i 25%

l l

! The required inspection interval shall not be lengthened

• more than one step at a time.

i Snubbers may be categorized in two groups, " accessible" or l

" inaccessible" based on their accessibility for inspection during reactor operation. These two groups may be in-l spected independently according to the above schedule.

l (2) All hydraulic snubbers whose seal materials are other than eythlene propylene or other material that has been de-monstrated to be compatible with the operating environment shall be visually inspected for operability every 31 days.

Amendment No. 27 3-77

(

3.0 SURVEIU.ANCE REQUIRDENTS 3.14 Shock Suppressors (Snubbers) (Continued)

(3) At least once per 18 months during shutdown, a represent-ative sample of 88 snubbers shall be functionally tested either in-place or in a bench test. For each nu=ber of snubbers above 3 which does not =eet the functional test '

acceptance criteria, an additional sa_ple selected according to the expression 22(a-3) shall ne functionally tested, where a is the total number of snubbers found inoperable during the functional testing of the representative sa=ple.

For each inoperable snubber found during a resa=ple test, an additional 22 snubbers will be tested until no additional inoperable snubbers are found within a sa=ple or until all i snubbers in Table 2-6 (a) and (b) have been functionally tested. -

The representative sample selected for functional testing shall include the various configurations, operating en-vironments and the range of size and capacity of snubbers.

At least 25% of the snubbers in the representative sample t shall include snubbers from any of the following three categories:

(a) The first snubber away from each reactor vessel nozzle.

t (b) Snubbers within 5 feet of heavy equipment (valve, t pump, turbine, motor, etc). t (c) Snubbers within 10 feet of the discharge frca a safety relief valve.

Snubbers identified in Table 2-6 (a) and (b) as "Especially Difficult to Remove" or in "High Radiation Zones During Shutdown"~shall also be included in the representative sample.*

In addition to the regular sample, snubbers which failed the ,

previous functional test shall be retested during the next test-period. If a spare snubber has been installed in place of a failed snubber, then both the failed snubber (if it is j.

repaired and installed in another position) and the spare -

anubber shall be ratested. Test results of these snubbers may not be included for the resampling.

-* Permanent or other exemptions from functional testing for individual

snubbers in these categories may be granted by the Commission only if a justifiable basis for. exemption is presented and/or snubber life destructive testing was performed to qualify snubber operability for all design conditions at either the completion of their. fabrication

~

or at a subsequent date.

Amendment No. 27 3-78

1. ..

3.0 SURVEILLANCE REQUIREHENTS 3.14 Shock Suppressors (Snubbers) (Continued)

If any snubber selected for functional testing either fails to lockup or fails to move, i.e., is frozen in place, the cause will be evaluated. If the cause is a manufacturer or design deficiency, appropriate action shall be taken for snubbers of the same design subject to the same defect to determine if any more defects exist. This testing require-ment shall be independent of the requirements stated above for snubbers not meeting the functional test acceptance criteria.

For any snubber (s) found locked up during normal operation or found inoperable during a seismic event, an engineering evaluation shall be performed on the components which are supported by the snubber (s). The purpose of this engineer-ing evaluation shall be to determine if the components sup-j ported by the snubber (s) were adversely affected by the inoperability of the snubber (s) in order to ensure that the

! supported component remains capable of meeting the designed service. If the engineering evaluation shows the components to be capable of meeting the designed service without the failed snubber, that snubber may be deleted from service and Table 2-6 (a) and (b) per Specification 2.18(4).

l

! (4) Snubber Service Life Monitoring h A record of the service life of each snubber, the date at j which the designated service life commences and the in-stallation and maintenance records on which the designated service life is based shall be maintained as required by Specification 5.10.2 m. At least once per 18 months the

installation and maintenance record for each snubber listed

- in Table 2-6 (a) and (b) shall be reviewed to verify that the indicated service life has not been exceeded or will not be exceeded prior to the next scheduled snubber service life review. If the indicated service life will be exceeded

prior to the next scheduled snubber service life review, the i

snubber service life shall be re-evaluated or the snubber shall be replaced or reconditioned so as to extend its ser-l vice life-beyond the date of the next scheduled service life i

review. This re-evaluation, re?lacement or reconditioning ,

shall be indicated in the records.

Basis All snubbers listed in Table 2-6 (a) and (b) are required operable l

to ensure that the structural integrity of the reactor coolant

! system and all other safety-related. systems is maintained during and following a seismic or other event initiating dynamic loads.

The visual-inspection frequency is based upon maintaining a constant level of snubber protection to systems. Therefore, the required inspection interval varies inversely with the observed snubber failures and is determined by the number of inoperable before that interval has elapsed may be used as a new reference Amendment No. 27 3-79

- _- _ _ = - _ - . - - -

i e e

• 3.0 SURVEILLANCE REQUIREMENTS 3.14 Shock Suppressors (Snubbers) (Continued) point to determine the next inspection. However, the results of such early inspections performed before the original required time

' interval has elapsed (nominal time less 25%) may not be used to lengthen the required inspection interval. Any inspection whose results require a shorter inspection interval will override the previous schedule.

When a snubber is found locked up or frozen in place or when a snubber has been inoperable during a seismic event, an engineering evaluation shall be performed, in addition to the determination of the snubber mode of failure. The purpose of the engineering evaluation is to determine if any safety-related component or system has been adversely affected by the inoperability of the snubber. The engineering evaluation shall determine whether or not the snubber mode of failure has imparted a significant effect or degradation on the supported component or system.

To provide assurance of snubber functional reliability, a repre-sentative sample of the installed sntAbers will be functionally tested during plant shutdowns at 18 month intervals. Selection of a representative sample according to the expression 35(1+c/2)*

provides a confidence level of approximately 95% that 90% to 100%

of the snubbers in the plant will be operable within acceptance limits. Observed failures of these sample snubbers shall require functional testing of additional units. For each number of snubbers above c which does not meet the functional test ae-ceptance criteria, an additional sample selected according to the expression 35(1+c/2)(2/(c+1))2(a-c) will be functionally tested, where a is the total number of snubbers found inoperable during the functional testing of the representativa sample. Functional testing will continue according to the expression b(35(1+c/2)(2/(c+1))2)

- where b is the number of snubbers found inoperable in the previous resample, until no additional inoperable snubbers are found within a sample or until all snubbers in Table 2-6 have been functionally tested.

Hydraulic snubbers and mechanical snubbers will each be treated as a different entity for the above surveillance programs.

The service life of a snubber is evaluated via manufacturer input ,

and information through consideration of the snubber service conditions and associated installation and maintenance records (newly installed snubber, seal replaced, spring replaced, in high radiation area, in high temperature area, etc.). The requirement to monitor the snubber service life is included to ensure that the snubbers periodically undergo a performance evaluation in view of their age sad operating conditions.. These records will provide statistical bases for future consideration of snubber service life. The requirements for the maintenance of records and the snubber service life review are not intended to affect plant operation.

• The value c will be arbitrarily chosen by the applicant and incorporated into the expression for the representative sample and for the resample prior to the issuance of tha Technical Specifications.

3-79a

. s e e

• 5.0 ADMINISTRATIVE CONTROLS 5.10.2 The following records shall be retained for the duration of the

-Facility Operating License:

a. Records of drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.

b. Records of new and irradiated fuel inventory, fuel trans-fers and assembly burnup histories.

c. Records of facility radiation and contamination surveys.

d. Records of radiation exposure for all individuals entering radiation control areas.

e. Records of gasecus and liquid radioactive material re-leased to the environs.

f. Records of transient or operational cycles for those facility components designed for a limited number of transients or cycles.

g. Records of training and qualification for current members of the plant staff.

h. Records of in-service inspections erformed pursuant to these Technical Specifications.

1. Records of Quality Assurance activities required by the QA Manual.

j. Records of reviews performed for changes made to pro-cedures or equipment or reviews of tests and experiments l pursuant to 10 CFR 50.59.

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k. Records of meetings of the Plant Review Committee and the Safety Audit and Review Committee.

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1. Records of Environmental Qualification which are covered

( under the provisions of Section 5.12 of these Technical

( Specifications.

m. Records of the service lives of all hydraulic and mechanical snubbers listed on Table 2-6 (a) and (b) including the date at which the service life commences and associated install-L- ation and maintenance records.

5.11 Radiation Protection Prograr, ,-

Procedures for personrLi r J;.-ion protection shall be prepared consistent with the I.*qsl/c5 es of 10 CFR Part 20 and shall be approved,_ maintained sad adaux4d to for all operations in-volving personnel radiation exposure.

Order dated: October 24, 1980 5-19 u.

DISCUSSION The proposed revisions to the Fort Calhoun Station Unit No. 1 Technical Specifications are intended to provide the following func-tions:

1. Respond to the Commission's letter dated Novenber 20, 1980.

2. Incorporate several changes, clariri +1ons, and improvements from the previous version involving surveillance testing and inspection of snubbers. These changes were based on recent operating experience.

3. Update Table 2-6, " Accessibility of Safety-Related System Snubbers".

One of the major changes is the method of determining the repre-sentative sample size and the resample sizes for functional testing of the snubbers. The present Technical Specificatiot.s state that 10 snubbers, or 10% of the. total population, constitute a representative sample size and, for each snubber found inoperable in the representative sample, an additional 10 snubbers, or 10%, must be tested. The proposed Technical Specifications use the formulas based on an arbitrary value of c to determine representative and resa=ple sizes. The District has selected a value of e equal to 3. Therefore, the representative sample will include 88 snubbers. If 3 snubbers or less are found to be in-operable, then no resample will be required. For each additional in-operable snubber over 3, 22 more snubbers will be tested. For each inoperable snubber in the resample, an additional 22 snubbers will be tested.

In response to NRC concerns identified in IE Bulletins 79-02 and 79-14 about the adequacy of seismic analysis documentation for safety-related piping systems, Gilbert / Commonwealth Associates was hired to

reanalyze all safety-related systems and generate complete seismic analysis documentationtfor the Fort Calhoun Station. The method of l analysis used is a response spectrum modal analysis using appropriate

! floor response spectra as input, in accordance with Appendix F, Section F.2.5, Item (C), Page F-19, of the Fort Calhoun FSAR. The computer package used by G/C to perform this analysis is a verified version of the T-PIPE code developed jointly by PMB System Engineering and Ten- -

nessee Valley Authority.

l The dynamic method used by G/C is more refined than the original static method used'in the original plant design. As a result of the

.added sophistication, some of the snubbers presently attached to safety i systems have been shown by analysis to serve no safety function (i.e.,

removal of these snubbers will not impair the ability of the associated piping system to withstand design conditions). In order to eliminate ATTACHMENT B

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F-needless surveillance testing, the following snubbers have been deleted from Table 2-6 (a) and will be physically removed from the piping.

Tag No. Subsystem No.' Analysis I.D. Analysis Revision No.

FWS-72 FW-289A VEFNEO Rev. 0 FWS-72A FW-289A VEFNJXO Rev. O SIS-62 SI-212A VH01JD1 Rev. 1 ACS-296 AC-086C KWEFANF Rev. 1 SIS-133 SI-074C GLQLR8D Rev. 2 Snubbers have also been added at various locations for a variety of systems, as a result of the reanalysis. These additions ensure that sections of safety-related piping are rigid as defined in Appendix F, Section F.2.2.2,~Fage F-7, and specified in Section F.2.5, Page F-11, of

! the FSAR. The snubbers which should be added to the current list of Technical Specification snubbers is as follows:

Tag No. Subsystem No. Analysis I.D. Analysis Revision No.

t ACS-385 AC-215A VEBFJVM Rev. O RWS-128 RW-231A OTRSMER Rev. O RWS-130 RW-231A OTRSMER Rev. O RWS-131 RW-231A OTRSMER Rev. O SIS-208 SI-197A VKSXJTD Rev. 2 SIS-202 SI-195A VKUHJ8D Rev. 1 SIS-204 SI-201A VCRKJ72 Rev. 1 SIS-205 SI-209A VGNVJZO Rev. 2 SIS-206 SI-209A VGNVJZO -Rev. 2

-During the review of "As Built" piping systems for NRC IE Bulletin 79-14,~a few snubbers, which were part of the Main Steam System for which dynamic analysis documentation was available, were found to be missing. To ensure that the related piping conformed to the available dynamic analysis, these snubbers were installed at the appropriate locations. . The following snubbers have been added to Table 2-6 (a):

Additions (Analysis performed by NSC and documented in the FSAR, AEC Docket No. 50-285, May 1973)

Tag No. Norm Access ' Norm Inaccess -

MSS-9 X MSS-9A X MSS-13 X During the analysis of baseplates and anchors for NRC IE Bulletin 79-02, one restraint was identified ~as being unstable as designed and could not be credited with performing its intended function. To correct

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the unstable design, an additional snubber was added in parallel with the existing snubber at that location. This modification created a top and bottom snubber arrangement. Therefore, Table 2-6 (a) should be changed to show:

Delete SIS-119 Add SIS-119 Top SIS-119 Bottom There was also Lte snubber name change from SIS-174BB to SIS-176.

This was the only snubber with a double letter designation, so the change was made to be consistent and avoid confusion. There are a few other snubbers added to Table 2-6 (a) that were installed previously but were not listed la the Technical specifications before. After re-evaluation, it has since been determined that these snubbers should be included in Table 2-6 (a). As a result, Table 2-6 (a) should be changed as follows:

Delete SIS-174BB Add SIS-29 SIS-176 SIS-178 It is concluded that, based on the following reasons, the proposed Technical Specifications do not involve an unreviewed safety question per 10 CFR Part 50, paragraph 50.59(a)(2):

1. The proposed changes do not increase the probability or consequences of accidents or malfunction of safety-related equipment previously considered.

2. There is a reasonable assurance that the health and safety of' the public will not be endangered under the proposed changes.

3. The possibility for an accident or malfunction of a different type than previously evaluated is not created.

4. The margin of safety, as defined in the applicable Technical Specifications, is not reduced.

A comparison of the Standard Technical Specifications attached to the Commission's letter dated November 20, 1980, versus the proposed Technical Specifications is presented on the next page.

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COMPARISON OF STANDARD TECHNICAL SPECIFICATIONS (STS)

AND PROPOSED TECHNICAL SPECIFICATIONS FOR FORT CALHOUN STATION UNIT NO. 1 Section or Section or Subsection Subsection of STS Proposed TS Remarks

1. 3.7.9 2.18 Operating Modes 1, 2, 3, and 4 Applicability Applicability in the STS correspond to Oper-ating Modes 1, 2, and 3 in the Fort Calhoun Station Technical Specifications. Operating Modes 5 and 6 in the STS are similar to Operating Modes 4 and 5 in the Fort Calhoun Station Technical Specifications.

2. N/A 2.18(3) (c) "Only one snubber listed in Table 2-6" has been changed to "Only one snubber station, containing snubbers listed in Table 2-6 (a) & (b)".

This will allow more than one snubber in the same location on the same system to be re-moved, if necessary, without

• affecting the safety of the system.

3. N/A 2.18(4) This statement was added to allow the District to add, change, or delete snubbers listed in Table 2-6 (a) & (b) without prior notice if an updated, approved engineering ,

analysis justifies such changes.

Any revisions will be included in subsequent licensing requests.

4. 4. 7. 9 (b) 3.14(1) The section on " Visual Inspection Acceptance Criteria" has been deleted in order to be consistent with the existing Section 3.14 and other similar sections of the Fort Calhoun Station Technical Specifications. The District feels that detailed acceptance

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criteria are too cumbersome for

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Technical Specifications and are more appropriately placed in the specific surveillance procedures.

The District therefore intends to include acceptance criteria in ST-HSS-1, 2, and 3_for sur-ve111ance of hydraulic snubbers.

Subsection Subsection of STS Proposed TS Remarks

5. 4.7.9(c) 3.14(3) The STS leaves the option of test-paragraphs paragraphs ing 10% of the total nu=ber of 1 and 2 1 and 2 snubbers or following the for=ula of 35(1+c/2) to deter =ine the representative sa=ple size.

The District has chosen the formula 35(1+c/2) with c = 3

',see remarks in discussion).

6. 4.7.9(c) 3.14(3) /aragraph 7 of the STS requires paragraph 7 an engineering evaluation to determine if the system has been adversely affected for each inoperable snubber. There are two ways by which the system could be adversely affected:

1) if a seis=ic event occurred while a snubber was inoperable, or 2) if a snubber beca e locked up or frozen in place during normal operation preventing thermal =ovement of the sup-ported co=ponent. For a pas-sive failure, such as leakage of fluid, the snubber would still allow the supported com-ponent to move freely so the system would not be adversely affected unless a seismic event occurred while the snubber was

- inoperable. If the engineering evaluation shows the components to be capabl( of meeting the de-signed' service without the failed snubber, that snubber may be de-leted from service and Table 2-6 (a) and (b) per specification j 2.18 (4) . Deletions will be allowed only after an independent review .

of the engineering justification is performed and the deletions are

. approved by SARC.

7. 4.7.9(d) : 3.14 (3) The section on !' Hydraulic Snubbers Functional Test Acceptance Criteria"

- has been deleted in order to be con-sistent with the existing-Section 3.14 and other similar sections of-the Fort Calhoun Station Tech-nical Specifications. 'The District feels that detailed

Section or Section or Subsection Subsection of STS Proposed TS Remarks

7. (Continued) acceptance criteria are too cum-bersome for Technical Spesifi-cations and are more appropriately placed in the specific surveillance procedures. There are, in fact, acceptance criteria already out-lined in ST-HSS-4 for functional testing of hydraulf.c snubbers.

8. 4.7.9 3.14 The statement " snubbers excluded Basis Basis from this inspection program are paragraph l' paragraph 1 those installed on non-safety related systems and then only if their failure or failure of the system on which they are installed would have no adverse effect on any safety-related system" has been replaced by "all snubbers listed in Table 2-6 (a) and (b) are required operable". This list meets all of the requirements of, and is more specific than, the pre-ceding statement.

9. 4.7.9 3.14 The wording has been changed Basic Basis from " inoperable snubber" to paragraph 4 "a snubber that is locked up or frozen in place during normal operation or when a snubber is inoperable during a seismic event" (see remarks for No. 6).

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• JUSTIFICATION FOR FEE CLASSIFICATION The proposed amendment is deemed to be a Class III amendment in that it involves a single safety issue, snubber surveillance, and its acceptability has been identified by a Commission position, as detailed in the Commission's letter dated November 20, 1980.

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